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### Njo, Heather

From: Schaeffer, John Sent: Wednesday, December 18, 2013 3:15 PM To: Henry L. Ritell Cc: Lewis, Paul; Mattheisen, Mike; Njo, Heather Subject: 127-68-4 RE: Sodium Metabenzene Sulfonic Acid - Section 4 TOSCA 127-684

Dear Mr. Ritell, RE: Compliance with Testing Requirements under TSCAsection 4 for CASRN 127­68­4 EPA understands the necessity you expressed for add itional time due to the Holidays, and is granting R it­ Chem Co., Inc. a 45 day extension to respond to the Agency regardingthis matter. With this extension, Rit­Chem’s resp onse is due Monday, February 3, 2014. Have a good Holiday season,

John Schaeffer Senior Biologist USEPA/OPPT/CCD/CITB 1201 Constitution Ave, NW Washington, DC 20460 Mail Code: 7405M Phone: 202-564-8173

From: Henry L. Ritell [ mailto:hritell@ritchem.com ] Sent: Tuesday, December 17, 2013 3:00 PM To: Schaeffer, John Subject: Sodium Metabenzene Sulfonic Acid - Section 4 TOSCA 127-684 Dear Mr. Schaeffer, Thank you for your e­mail dated November 25 th , relative to the subject matter. As explained, Ri t­Chem Co., Inc. was never officially apprised of a need to register or test the chemical in question. This product has be en officially registered by several manufacturers domestically and foreign i n order to be listed on the Tosca List, going back at least 25­50 years. Rit­Chem Co., Inc. is not a producer, but imports w hen and if the product SMNBS is required. Secondly , once a product receives a TOSCA designation, which requires specif ications, toxicity studies etc., it normally does n ot compel new manufacturers of the same product to “reinvent the wheel.” As indicated during our discussion, once Tiarco Che mical Co., (their choice since they are the only do mestic producer) decided to purchase the old Crown Metro plant in 20 06, they had to comply with the EPA requirements. We understood Tiarco Chemical has already completed th eir tests and received final approval. Rit­Chem Co ., Inc. has not had to face this dilemma, since we chose years ago not to even consider manufacturing SMNBS. This pro duct has always been plagued with pollution problems in manufacturi ng and unable to be competitive with 3 rdworld countries. All that being said, Rit­Chem is first of all, requ esting more time to seriously consider our options. This request is based on the fact that Tiarco Chemical only brought it to our attention in October. Secondly, knowing the h istory and the logic submitted herewith, we may consider applying for ex emption. There are many legal ramifications involv ed herein such as procedures empowering Tiarco Chemicals with a mo nopoly in the USA. The encouragement by the EPA to have other2 companies collude with the only domestic manufactur er of SMNBS in the USA is contrary to free trade an d basically illegal! Rit­Chem Co., Inc. will alternately contact Tiarco Chemical to determine how realistic they are as the umbrella to permit other companies to survive competitively. Please also bear in mind, Rit­Chem Co., Inc. is a s mall Chapter S family owned business with no manufa cturing facilities! To conclude, we have already contacted Tiarco Chemi cal and are awaiting their response to our offer to negotiate a reasonable onetime payment settlement. Please referto the attached letter by our Vice­President of Pu rchasing & Logistics, Mr. Bruce Ritell to Mr. Kevin J. Nolan, Vice­President/General Manager of Tiarco Chemical. Obviously, RitChem Co., Inc. will be in compliance as soon as Tia rco completes their negotiations with Bruce Ritell. We have been assured by Tiarco Chemical that they w ill be discussing our decision with the EPA, presum ably with you. Again, we do require an extension of possibly 45­60days because of the Christmas festive holidays, an d the awaiting of final negotiations between Bruce Ritell and Kevin N olan, et. al. Thank you for your considerations and cooperation! Sincerely, Henry L. Ritell ­ President Rit­Chem Co., Inc. Thornwood, New York, USA Ph: 1­914 769­9110 Fx: 1­914 769­1408 E­Mail: hritell@ritchem.com